Part 66(L) Licensed Engineers issuing Certificates of Release to Service for balloons are subject to the recency requirements defined in Part 66. Under Rule 66.A.20(b)2, the definition is 6 months work in the preceding 2 years. This is clarified in the Acceptable Means of Compliance AMC 66.A.20(b)(2) as 100 days for Engineers working for a Maintenance Organisation and 50 days for Independent Certifying Staff. These requirements are very difficult, or impossible, to meet for many balloon Engineers, who work on a very part-time basis, often at weekends only, in summer and sometimes on a voluntary basis.
EBF has been working with EASA, alongside EGU (the European Gliding Union) and EAS (Europe Air Sports) to find other routes to support legal recency of balloon (and glider) Engineers.
When a licence is initially issued, the holder can rely on the practical experience acquired during their training for legal recency, instead of the 6 months requirement, during the first 2 years of holding the licence. This is stated in the Guidance Material GM 66.A.20(b)2.
EASA has committed to changing the requirements (via rule-making in the coming 1-2 years) to enable recency to be supported at all times by practical experience equivalent to that required for the issue of the balloon Engineer rating. This would then be an alternative route for legal recency for Engineers who do not meet the (rolling) requirement of 100 days work in the previous 2 years. Using the new interpretation, only practical work is considered: there is no requirement for any repeat of theoretical study or examinations.
Under the new interpretation, Engineers will need to be demonstrate, by logbook or other work record evidence, that a “representative cross section of maintenance tasks” have been undertaken in the preceding 2 years.
EASA, EBF, EGU and EAS are working on agreed examples of “representative sets of maintenance tasks”. There is a list of tasks for balloon Engineers given in Appendix II to AMC to Annex III section (1)C of Part 66. Some of these tasks are never, or very rarely done as a working Engineer, even though they may be covered during training. The Part 66 list should be considered a list of possible tasks, from which any Engineer can take those which are relevant and representative of their own specific work as a balloon Engineer.
A “representative set of maintenance tasks” will vary from Engineer to Engineer. For example, if an Engineer primarily works on annual inspection and on rectification of defects arising from annual inspections, then their recency could be based on doing a reasonable number of such inspections and follow-up maintenance actions. EBF believes that the Part 66 task list specification for annual inspections (including follow-up maintenance) would be the bare minimum (per 2 years). This is defined as 8 inspections across at least 3 types (manufacturers) of balloons. For most Engineers, it would be expected that this bare minimum would be supplemented by other maintenance work and/or more annual inspections.
EBF will provide updates as the work to define “representative set of maintenance tasks” continues.
For Engineers working through a maintenance/airworthiness organisation (usually a CAO), the CAO approves the work an Engineer may undertake, considering factors such as task-specific recency as well as competence. In the case of Independent Certifying Staff, they are accountable directly to their NAA for their recency monitoring.
EASA has updated its Frequently Asked Question FAQ 19023 on Part 66 Engineer recency. This FAQ covers all such Engineers, so is somewhat complex. The full text is here: Is there a requirement to have 6 months’ experience every 2 years to maintain the validity of the Part-66 licence? | EASA
The key points for balloon Engineers are summarised (by EBF) as follows below. Please note the clear commitment from EASA in the final sentence to update Part 66 in the near future.
| EXTRACT from EASA FAQ 19023 as relevant for Part 66L Engineers working on balloons As holder of an aircraft maintenance licence, to exercise your certification privilege in accordance with 66.A.20(b)(2), please ensure: • You have accumulated 6 months of experience in the previous 2 years; Note: see also AMC 66.A.20(b)(2) for possible reductions of experience, in particular for independent certifying staff. Demonstration of experience should be made on the particular or similar aircraft. Guidance on ‘similar’ aircraft is also provided in AMC 66.A.20(b)(2). or • You can demonstrate that in the last 2 years, you have met the provisions for the issue of appropriate privileges, which means (refer to 66.A.45), as applicable to the case: – for L-category licences (other than L5), being able to demonstrate, in the last 2 years, practical experience, which shall include a representative cross section of maintenance activities relevant to the licence subcategory (B2/B2L, L1, L1C, L2, etc.) Note: “A representative cross section of maintenance activities” means representative cross-section of the tasks listed in Appendix II to AMC to Annex III (Part-66) “Aircraft Type Practical Experience and On-the-Job Training – List of Tasks”. “Demonstrate” means having a record thereof, such as a logbook. Note: GM 66.A.20(b)2 will be reviewed and amended according to this interpretation through rulemaking task RMT.0735. |
For any questions, contact Paul Spellward, psp@ballooning-federation.eu